Liberi V Taitz - Berg Motion For Injunction/tro - 3

Case 2:09-cv-01898-ER

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Filed 06/23/2009

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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al, Plaintiffs,

vs.

ORLY TAITZ, et al, Defendants.

: : : Assigned to Honorable Eduardo C. Robreno : : : Case No.: 09-cv-01898-ECR : : : :

ORDER AND NOW, this _____ day of June, 2009, it is hereby ORDERED and DECREED that: (1)

A Restraining Order is issued. Defendants’ Orly Taitz a/k/a Dr. Orly Taitz

a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey Firm, Sankey Investigations, Inc., Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Braun a/k/a Web Sergeant a/k/a Katy a/k/a www.obamacitizenshipdebate.org; Edgar (Ed) Hale a/k/a JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains Radio; and KPRN AM 1610 and all parties acting on their behalf are enjoined from airing and/or publishing any defamatory or false statements about Plaintiffs’, Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa Ostella, the Plaintiffs’ family members, etc. via the internet or any other print or electronic medium or broadcasts and/or radio, from portraying Plaintiffs’ in a false-light via the internet or

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another print or electronic medium or broadcasts and/or radio, untrue statements about the Plaintiffs’; (2)

Defendants’ Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly

Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey Firm, Sankey Investigations, Inc., and all parties acting on their behalf are enjoined from disseminating, publishing, e-mailing, posting and distributing Liberi’s Social Security number, date of birth, mother’s maiden name, residency, place of birth and all other personal identifying information; (3)

Defendants’ Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly

Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey Firm, Sankey Investigations, Inc., Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Braun a/k/a Web Sergeant a/k/a Katy a/k/a www.obamacitizenshipdebate.org; Edgar (Ed) Hale a/k/a JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains Radio; and KPRN AM 1610 are enjoined from any further harassment; invasion of privacy; violation of rights to privacy; cyber stalking; cyber harassment; cyber invasion of privacy; of the Plaintiffs’; (4)

Defendants’ Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly

Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation, Inc., are enjoined from the filing and reporting of falsified criminal activity, etc; (5)

Defendants Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly

Taitz a/k/a Orly Taitz, Inc., Defend our Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations and any party who has published Lisa Liberi’s confidential information and false accusations of criminal activities posted, published,

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disseminated about Lisa Liberi on their behalves to immediately retract and remove Lisa Liberi’s private confidential information, including but not limited to her Social Security number, date of birth, where she resides, mother’s maiden name; father’s name; place of birth; information about her husband, the false criminal accusations; (6)

Defendants’ Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly

Taitz a/k/a Orly Taitz, Inc., Defend our Freedoms Foundation, Inc., and anyone on their behalf are enjoined from disseminating, publishing, e-mailing, posting and distributing Lisa Ostella’s personal and confidential information, including but not limited to her home address, telephone number and maiden name; (7)

Defendants’ Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly

Taitz a/k/a Orly Taitz, Inc, Defend our Freedoms Foundation, Inc., and any party who has published Lisa Ostella’s confidential information and false accusations of criminal activities posted, published, disseminated about Lisa Ostella on their behalves to immediately retract and remove Lisa Ostella’s private confidential information, including but not limited to her home address, telephone number and maiden name and the false criminal accusations; (8)

Defendants’ Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly

Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey Firm, Sankey Investigations, Inc., James Sundquist; Rock Salt Publishing; Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a Stitchenwitch

a/k/a

Eva

Braun

a/k/a

Web

Sergeant

a/k/a

Katy

a/k/a

www.obamacitizenshipdebate.org; Edgar (Ed) Hale a/k/a JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains Radio; and KPRN AM 1610 are

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ORDERED to retract all slander and libel disseminated, posted, published and e-mailed about Plaintiffs’ Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa M. Ostella and Go Excel Global; (9)

Defendant’s Orly Taitz, Esquire a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a

Law Offices of Orly Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation are ORDERED to issue a cashiers check in the amount of Twenty Thousand [$20,000.00] Dollars payable to Lisa Liberi through this Court within seventy-two [72] hours; (10)

Defendant’s Orly Taitz, Esquire a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a

Law Offices of Orly Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation are ORDERED to pay Plaintiffs’ Counsel, Philip J. Berg, Esquire Attorney fees in the amount of Five Thousand [$5,000.00] Dollars; and (11)

The Social Security Administration is ORDERED to immediately issue a

new Social Security number to Plaintiff Lisa Liberi in order to ensure her safety.

IT IS SO ORDERED:

Date: June _____, 2009

______________________________ U.S. District Judge Eduardo C. Robreno, J.

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Law Offices of: PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134

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Attorney for: Plaintiffs

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al, Plaintiffs,

vs.

ORLY TAITZ, et al, Defendants.

: : : Assigned to Honorable Eduardo C. Robreno : : : Case No.: 09-cv-01898-ECR : : : :

PLAINTIFFS’ EMERGENCY MOTION FOR THE ISSUANCE OF PLAINTIFFS’ INJUNCTION or RESTRAINING ORDER REQUESTED IN PLAINTIFFS’ MOTION FILED and DOCKETED as DOCUMENT NO. 3 ON MAY 4, 2009 NOW COMES the Plaintiffs’, Lisa Liberi [hereinafter “Liberi”], Philip J. Berg, Esquire [hereinafter “Berg”], the Law Offices of Philip J. Berg, Evelyn Adams a/k/a Momma E [hereinafter “Adams”], Lisa Ostella [hereinafter “Ostella”] and Go Excel Global by and through their undersigned counsel and respectfully requests this Honorable Court to grant their Emergency Injunction or a Restraining Order against Defendants’, Orly Taitz, Esquire a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc [hereinafter “Taitz”]; Defend our Freedoms Foundation; Neil Sankey [hereinafter “Sankey”]; The Sankey Firm, Sankey Investigations, Inc; Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a

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Stitchenwitch

a/k/a

Eva

Document 66

Braun

a/k/a

Filed 06/23/2009

Web

Sergeant

www.obamacitizenshipdebate.org [hereinafter “Belcher”];

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a/k/a

Katy

a./k/a

Edgar (Ed) Hale a/k/a JD

Smith [hereinafter “Mr. Hale”]; Caren Hale [hereinafter “Mrs. Hale”]; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains Radio [hereinafter “Plains Radio”]; and KPRN AM 1610, on the following grounds: 1.

Plaintiffs’ filed for an Emergency Injunction or Restraining Order on May

4, 2009 appearing on the Docket as document number 3.

To date, this Motion has

not been ruled upon and the Defendants’ behaviors have intensified. Inasmuch, Plaintiffs’ have been suffering serious damages. 2.

Plaintiffs’ hereby incorporate by reference their original May 4, 2009 Motion for an Emergency Injunction [Doc. #3] and their Complaint filed May 4, 2009, [Doc. #1] as if fully set forth herein.

3.

As set forth in detail below, Plaintiffs are in immediate need of an Emergency Injunction or Restraining Order to prohibit further violations of the following by the Defendants’: •

The disclosure, posting on the internet, sending through RSS Feeds, e-mailing, etc. of Plaintiff, Lisa Liberi’s Social Security number, date of birth, mother’s maiden name, where she was born and other confidential private information. in violation of State and Federal Laws, e.g. the Social Security Act, California Privacy Laws, Civil Code §1798 et sequitur; Identity Theft and Assumption Deterrence Act, 18 U.S.C. §1028(a)(7); Pennsylvania Privacy Acts (74 Pa. Stat. Ann. § 201 (West 2006); California Business and Professions Code 22577(a); the Electronic Communications Privacy Act, 18 U.S.C. §§2510-22, and the Stored Communications Act, 18 U.S.C. §§2701-11.

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Cyber harassment, Cyber stalking, etc. in violation of the Women’s Violence Act, Department of Justice Reauthorization Act of 2005, H.R. 3402, titled "Preventing Cyber stalking" and numbered as § 113, §113(a)(3) provides that Section 223(a)(1)(C) applies to "any device or software that can be used to originate telecommunications or other types of communications that are transmitted, in whole or in part, by the Internet; Cyber-stalking and Cyber-harassment laws in violation of the Communications Act, 47 U.S.C. § 223(a)(1)(C) and § 223(h)(1)(B).

4.

•

Slander and Libel.

•

Harassment.

•

Calling for individuals in the locations which Plaintiffs’ reside.

Plaintiffs’ Counsel appeared before Your Honor on May 4, 2009 when he

filed the above referenced action seeking an Immediate Temporary Injunction and/or a Temporary Restraining Order to prevent the harm the Defendants in the within action have and continue to cause. 5.

Your Honor stated once all the Defendants have been personally served

with the Summons, Complaint, the Emergency Motion for the Temporary Injunction, Memorandum of Law in Support of the Emergency Motion for a Temporary Injunction and/or Temporary Restraining Order to contact your chambers and inform you service was complete and Your Honor would set a phone conference for Counsel over this issue. Plaintiffs’ Counsel wrote to Your Honor on May 12, 2009 requesting a telephone conference. 6.

On May 11, 2009, Plaintiffs’ Counsel contacted your Honor’s chambers as

he was instructed to do to inform Your Honor all Defendant’s had been served with

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the exception of James Sundquist and Rock Salt Publishing. Counsel was instructed to send a letter, which he did on May 12, 2009. Counsel never heard back from Your Honor’s chambers. 7.

On May 14, 2009, Plaintiffs’ Counsel sent a second [2nd] letter to Your

Honor’s chambers Ex Parte as Defendant Taitz and Defend our Freedoms Foundation, Inc.’s behaviors were becoming more serious and Taitz had just released the information on a “Sealed case” of Plaintiffs Counsel.

On May 15, 2009,

Plaintiffs’ Counsel again called Your Honor’s chambers and was told Your Honor was reviewing the letter and someone would be back in touch. To date, no one from Your Honor’s Chambers has contacted my offices. 8.

Plaintiffs’ Counsel has attempted to have this matter heard before

Plaintiffs’ suffered any further injury, unfortunately, Counsel has been unsuccessful. 9.

All Defendants have been personally served. Despite being served, all the

Defendants, except James Sundquist and Rock Salt Publishing,have continued their illegal and harmful behaviors. In fact, Defendant, Orly Taitz, an Attorney, somehow obtained the information to a case of mine which was filed “Under Seal” and published it on her website at www.orlytaitzesq.com. At that time I wrote to Your Honor “Ex Parte” on May 14, 2009 requesting the entry of an Injunction or Restraining Order. 10.

Major

additional

problem

that

needs

Emergency

attention.

Yesterday, Monday, June 22, 2009, Defendant Orly Taitz, Esquire, et al has now published where Lisa Liberi was born and her mother’s maiden name. See EXHIBIT “1”.

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This coupled with the fact Ms. Taitz has published and still

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continues to publish Lisa Liberi’s full Social Security number and date of birth places Mrs. Liberi in serious risk of theft, identity theft, people can pull Mrs. Liberi’s credit file, etc., which Mrs. Liberi has absolutely no protections from. 11.

Mrs. Liberi will now suffer serious damages as a result of Mrs. Taitz

publication of Mrs. Liberi’s full Social Security number, date of birth, mother’s maiden name, where Mrs. Liberi was born, etc. To name a few, Mrs. Liberi is at serious risk of: a.

Birth Certificates from Washington State are public record; Anyone now can obtain Liberi's birth certificate and completely assume her identity.

b.

Anyone can now obtain Liberi's financial records; Social Security records; credit file (which has Liberi's home address).

c.

Anyone can obtain an Intellus report on Liberi now they have her Social Security number, date of birth, mother's maiden name, place of birth and father's name and obtain all Liberi's financial records, assets, etc.

d.

Anyone can apply for credit using Liberi's personal identifying information. Mrs. Taitz has now given them every aspect required to obtain credit.

e.

Mrs. Liberi must close all her current accounts and place freezes which means she will not have any open credit to use.

f.

Mrs. Taitz has called for people where Liberi resides and has called for the purging of Obama and his clique; she has called for Armed Rebellion against our Government; she has called for civilian militia that places Liberi, her kids and her husband in severe danger of bodily harm.

g.

Mrs. Liberi must now move, which means her husband will have to take off work, she will have to pay a large amount of money to get into a new residence, she will have to pay movers, plus pay to break her current lease; Liberi will have to pay disconnect and reconnection fees and again with absolutely no available credit to help her.

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12.

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h.

Mrs. Liberi must obtain a Court Order for the re-issuance of a new Social Security number and the re-issuance of a new Social Security number takes approximately 6-8 weeks and will not have any availability to credit and will have to start all over building a new credit history.

i.

Defendant, Orly Taitz should be immediately ordered to pay Lisa Liberi Twenty Thousand [$20,000] Dollars within 72 hours through this Court so Mrs. Liberi is able to take the above steps necessary to protect herself and family.

It is important to note, Mrs. Liberi’s Social Security number was

originally issued out of Texas, so no one was aware of where Mrs. Liberi was born, her mother’s maiden name, etc. It should also be noted, as a result of Orly Taitz, Esquire illegal actions, a woman in Texas is now using Mrs. Liberi’s Social Security number, see EXHIBIT “2”. 13.

Mrs. Liberi’s Social Security number was changed when she, her son and

her husband were issued a confidential address to protect them from further tracking and domestic violence she and her son were victims of. 14.

After service of the Complaint and other documents in this case,

Defendant Taitz continued sending our her Dossier #6, which has been previously submitted to this Court, with Lisa Liberi’s personal identifying information, including but not limited to name, date of birth and full Social Security number. Plaintiffs’ hereby incorporate all Exhibits, Exhibits “A” through “Q” attached to their Opposition [Doc. No. 63] to Defendant Orly Taitz, Esquire and Defend our Freedoms Foundation, Inc. Second Amended Motion to Dismiss. 15.

In addition, Plaintiff Lisa Ostella has lost every one of her clients as a

result of Mrs. Taitz illegal activities and falsified rumors. Plaintiffs’ have been

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harassed, their privacy completely invaded, their personal information posted on the Internet, sent in mass e-mailing (Orly Taitz Dossier #6 with Mrs. Liberi’s full Social Security number and other personal identifying information was sent to in excess of 140,000 individuals and companies, including internationally); Plaintiffs’ have been placed in a false light before the public, etc. This information has continued since the Defendants’ were served with the Complaint and Motion for an Injunction. 16.

Moreover, Mrs. Taitz is continuing her attempts to show some type of

connection between Mrs. Liberi and President Obama, including President Obama’s family, which is a total lie. This is important because Mrs. Taitz has called for the “purging” of President Obama and his clique, see EXHIBIT “3”. 17.

Mrs. Taitz through Defend our Freedoms Foundation as well the other

Defendants actions includes, just giving a few, but are not limited to:

•

Publication of Lisa Liberi’s full Social Security number, date of birth, where she was born, mother’s maiden name, etc.

•

The Hale Defendants & Sankey publicly announced Lisa Liberi had recently taken out a loan; The Hale Defendants stated they were given documents with Lisa Liberi’s confidential and private information by Neil Sankey, which Sankey collaborated on the Hale radio shows;

•

Mrs. Taitz through Defend our Freedoms Foundation, Inc. and the Sankey Defendants conspired and illegally altered and forged e-mails of Plaintiff Lisa Ostella;

•

Mrs. Taitz through Defend our Freedoms has called for people in the areas that the Plaintiffs’ reside; have called for information regarding financials, Social Security numbers, where they live, previous addresses, voting records, associations, etc. of Lisa Liberi and her husband; and Evelyn Adams and her husband;

•

Mrs. Taitz through Defend our Freedoms Foundation, Inc. have filed falsified law enforcement reports against Lisa Liberi and Lisa Ostella claiming these two Plaintiffs’ are one and the same and that they diverted

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funds from her PayPal Account; “hacked” her PayPal Account, stolen from her, the same allegations Mrs. Taitz made against “President Obama and his thugs;” and Danny Bickell, U.S. Supreme Court Clerk; •

Mrs. Taitz through Defend our Freedoms Foundation, Inc. have inferred Plaintiffs’ are President Obama’s “clique” and they are “Obots”, Mrs. Taitz through Defend our Freedoms Foundation, Inc. have called for the political “purging” of President Obama and his Clique. As this Court is aware, the definition of “purge” in the political sense is to “Kill”.

•

The Hales on their radio show, Plains Radio Network, Inc. have continued their slander and libel of Plaintiff Evelyn Adams, calling her heinous names, stating she is going to prison, falsely accusing Mrs. Adams of stealing their Obama divorce papers, falsely accusing Mrs. Liberi of removing the “watermark” from their divorce papers, falsely claiming Plaintiff Philip J. Berg is stealing people’s money, has no pending cases, is a shyster, etc.

•

Linda Sue Belcher, et al has continued her slander and libel of the Plaintiffs’ by stating Plaintiff Berg and Mrs. Liberi lied on Affidavits which were filed in the Federal Courts; claimed something was going to happen to Mrs. Liberi which will make Plaintiff Berg very unhappy; falsely inferred Plaintiff Berg is having affairs and stating she (Linda S. Belcher) was going to contact his significant other, Carol and tell her which will force Plaintiff Berg to call Mrs. Liberi a liar; threatening bodily harm to Mr. Berg and Mrs. Liberi if they step foot in her (Linda Belcher’s) neck of the woods which is the Western District of Texas where Linda Belcher is attempting to have this case moved; falsely accusing Mrs. Liberi and Mr. Berg of “tapping” her cell phone, etc.

18.

All of the above has been filed with this Court in Plaintiffs’ Briefs in

Opposition to Mrs. Taitz and Defend our Freedoms Foundation, Inc. frivolous filings. The events that took place prior to the filing of this lawsuit were included in Plaintiffs’ Complaint and Motion for an Emergency Injunction or Restraining Order. 19.

It should be noted by this Court, with the exception of Defendant’s Orly

Taitz, Esquire, et al and Defend our Freedoms Foundation, Inc, none of the other Defendants have opposed Plaintiffs’ Emergency Motion for an Injunction or Temporary Restraining Order prohibiting these illegal behaviors. In fact, Ms.

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Taitz and Defend our Freedoms Foundation, Inc. did “not” have “Standing” to file their Opposition to Plaintiffs’ Motion for the Emergency Injunction as Default had been entered and Judgment by Default packages had been filed with this Court prior to their late filings. 20.

James Sundquist and Rock Salt Publishing were originally named in this

suit for two (2) e-mails they sent out pertaining to Lisa Ostella. Defendant’s James Sundquist and Rock Salt Publishing are the only Defendant’s who have refrained from their illegal and tortuous behavior. In addition, Plaintiffs’ have a pending Motion for Leave to Dismiss Defendant’s James Sundquist and Rock Salt Publishing. 21.

Now that all Defendants have been personally served pursuant to this

Court’s Order, and with the exception of the Defaulted Defendants, have entered their appearances, and the continuance illegal behaviors of the Defendants’ which are causing continued harm to the Plaintiffs’, Plaintiffs’ through their counsel are requesting the issuance of the Emergency Injunction and/or Restraining Order. 22.

In addition, Plaintiffs’ through their undersigned counsel respectfully

request Five Thousand Dollars [$5,000.00] payable to Philip J. Berg, Esquire to cover the research and drafting of this brief, preparation and hearing on this matter.

WHEREFORE, Plaintiffs’ respectfully prays that this Honorable Court: A.

Grant Plaintiffs Motion for an Emergency Injunction and/or

Restraining Order prohibiting the Defendants’ from any further slander and/or libel;

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B.

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An immediate Order enjoining the Defendants’ Orly Taitz, Esquire

a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey Firm, Sankey Investigations, Inc; Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Braun a/k/a Web Sergeant a/k/a Katy a/k/a www.obamacitizenshipdebate.org; Edgar (Ed) Hale a/k/a JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains Radio; and KPRN AM 1610 and all parties acting on their behalf from airing and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi, Philip J. Berg, Esquire, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa Ostella, Go Excel Global, the Plaintiffs’ family members, etc. via the internet or any other print or electronic medium or broadcasts and/or radio, from portraying Plaintiffs’ in a false-light via the internet or another print or electronic medium or broadcasts and/or radio, untrue statements about the Plaintiffs’; enjoin the Defendants’ from any further harassment of the Plaintiffs’, enjoin Defendants’ from the filing and reporting of falsified criminal activity, etc. C.

An immediate Order enjoining Defendants Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party on their behalf from disseminating Liberi’s Social Security number, date of birth, name, where she was born, mother’s maiden name, where she lives, etc. D.

An immediate Order of Retraction against Defendants’ Taitz,

Defend our Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey

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Investigations, Inc., and any party who has published Liberi’s confidential information on their behalves to immediately retract and remove Liberi’s private confidential information, including but not limited to her Social Security number, date of birth, where she resides, her mother’s maiden name, where she was born, information about her husband, etc. E.

A Court Order directed at the Social Security Administration for

the Social Security Administration to issue Lisa Liberi a new Social Security number; F.

An immediate Order that Defendant Orly Taitz, Esquire and

Defend our Freedoms Foundation, Inc. immediately pay Twenty Thousand [$20,000.00] Dollars within in seventy-two [72] hours through this Court payable to Plaintiff Lisa Liberi for the relocation of Mrs. Liberi and her family as a result of the private confidential information Mrs. Taitz has posted, sent out via e-mail, sent out through the Internet RSS feed, etc. G.

Grant Plaintiffs’ Attorney fees in the amount of Five Thousand

Dollars [$5,000.00] payable to Philip J. Berg, Esquire within Seventy-Two [72] hours and such other and further relief as the Court deems just and proper. .

Respectfully submitted,

Dated: June 23, 2009

s/ Philip J. Berg _____________________________ Philip J. Berg, Esquire Attorney for the Plaintiffs’ 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134

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Law Offices of: PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134

Filed 06/23/2009

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Attorney for: Plaintiffs

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al, Plaintiffs,

vs.

ORLY TAITZ, et al, Defendants.

: : : Assigned to Honorable Eduardo C. Robreno : : : Case No.: 09-cv-01898-ECR : : : :

PLAINTIFFS’ MEMORANDUM OF LAW IN SUPPORT OF THEIR EMERGENCY MOTION FOR THE ISSUANCE OF PLAINTIFFS’ INJUNCTION or RESTRAINING ORDER REQUESTED IN PLAINTIFFS’ MOTION FILED and DOCKETED as DOCUMENT NO. 3 ON MAY 4, 2009 Plaintiffs’ hereby incorporate by reference their Complaint filed May 4, 2009 [Doc. #1] and their Motion for an Emergency Injunction and Memorandum of law in support thereto filed on May 4, 2009 [Doc. #3] as if fully set forth herein.

I.

PLAINTIFFS’ MEET THE BURDEN FOR THIS COURT TO ISSUE THE EMERGENCY INJUNCTION OR RESTRAINING ORDER:

The traditional standard for granting a Preliminary Injunction requires the Plaintiff to show that in the absence of its issuance he will suffer irreparable injury and also that he is likely to prevail on the merits. It is recognized, however, that a district

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court must weigh carefully the interests on both sides, Doran v. Salem Inn, Inc., 422 U.S. 922, 925 (U.S. 1975), Adams v. Freedom Forge Corp., 204 F.3d 475, 482 (3d Cir. Pa. 2000), AT&T v. Winback & Conserve Program, Inc., 42 F.3d 1421, 1427 (3d Cir. 1994); Acierno v. New Castle Cty., 40 F.3d 645, 653 (3d Cir. 1994); In re Arthur Treacher's Franchisee Litig., 689 F.2d 1137, 1143 (3d Cir. 1982). If relevant, the Court should also examine the likelihood of irreparable harm to the nonmoving party and whether the injunction serves the public interest. See AT&T v. Winback, 42 F.3d at 1427. Plaintiffs are plainly entitled to an Emergency Injunction and/or Temporary Restraining Order, pursuant to Rule 65 of the Federal Rules of Civil Procedure, to halt the dangerous and illegal behaviors of the Defendants’. Specifically, this Court must grant Plaintiffs Motion for an Emergency Injunction or Restraining Order because: (1) there is reasonable probability that Plaintiffs will succeed on the merits; (2) the Plaintiffs will suffer irreparable harm in the absence of relief; (3) there will be little or no harm to the Defendants’ if relief is granted; and (4) the public interest demands a grant of relief. See, e.g. Swartzwelder v. McNeilly, 297 F.3d 228, 234 (3rd Cir. 2002); Prison Health Servs., Inc. v. Umar, Civil Action No. 02-2642, 2002 U.S. Dist. LEXIS 12267 (E.D. Pa. May 8, 2002). The standards for a preliminary injunction and a TRO are the same. Mertz v. Houstoun, 155 F. Supp.2d 415, 425 n.12 (E.D. Pa 2001); Bieros v. Nicola, 857 F. Supp. 445, 446-47 (E.D. Pa. 1994). While the degree of probability of success on the merits required to obtain such relief varies among Federal Courts of Appeals, the U.S. Court of Appeals for the Third Circuit requires only a “reasonable likelihood” of success. See Johnson & Johnson Orthopedics, Inc. v.

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Minnesota Mining & Mfg. Co., 715 F. Supp. 110, 112 n.1 (D. Del. 1989). Plaintiffs easily meet each of the requirements for an Injunction or Restraining Order.

A.

Plaintiffs’ have already suffered and will continue to suffer irreparable, un-repairable Harm without the issuance of the Emergency Injunction or Restraining Order:

The mere fact Taitz through Defend our Freedoms Foundation, Inc., Sankey, the Sankey Firm, Sankey Investigations, Inc. have been distributing Liberi’s Social Security number, date of birth and now Liberi’s mother’s maiden name, where Liberi was born, etc. Liberi is at serious risk of individuals using her information, illegally obtaining credit, assuming Liberi’s identity, therefore this conduct must be stopped.

More

concerning is the fact Sankey through Sankey Investigations, Inc. and the Sankey firm admittedly furnished Liberi’s information to Defendants Edgar Hale, Caren Hale, Plains Radio Network, Inc. KPRN AM 1610 and Bar H. Farms who has publicized they have Liberi’s information on their Radio program, Plains Radio. Defendants’ Mr. Hale, Mrs. Hale and Sankey have admitted Liberi recently took out a loan, how did they know this unless they illegally pulled Liberi’s credit and/or applied for the loan themselves. This is serious and the Defendants must be stopped. As a result of Taitz through Defend our Freedoms Foundation, Inc. falsified statements regarding Plaintiff Lisa Ostella, Ostella has lost all of clients. Unless and until Taitz and Defend our Freedoms Foundation, Inc. are restrained from any further falsified publications, Ostella will not be able to rebuild her clientele and therefore has no way of earning a living. Plaintiff Berg’s damages and continued damages include loss of clients, he will be unable to secure any clientele that reads all the fabricated statements of the Defendants,

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and the continued harassment of all the Plaintiffs’, without the issuance of the within Emergency Injunction Plaintiffs’ privacy will continue to be violated, their personal family affairs broadcast and e-mailed through the Internet, they will continue to be placed in the false light before the public, they will be raped of their rights to privacy, the posting of their personal, private affairs as well as embarrassing facts will continue to be published through mass e-mailing and on the internet and on Defendant’s Mr. and Mrs. Hale’s radio program, Defendant, Plains Radio. Moreover, Taitz through Defend our Freedoms Network, Inc. have indirectly called for harm upon the Plaintiffs’. Sankey has already threatened to release where Liberi is located and now with the publication of Liberi’s Social Security number, date of birth, mother’s maiden name, etc., Liberi is very easy to be found and harmed, as well as the other Plaintiffs’. For the types of damages the Plaintiffs’ have already suffered and the irreparable harm they will continue to suffer, Plaintiffs’ will never be able to be compensated after the fact by monetary damages. In fact, Liberi is entitled to statutory damages totaling Four Hundred and Thirty Two Million [$432 Million] Dollars per the three [3] Defendants, Taitz, Defend our Freedoms Foundation, Inc; and the Sankey Firm and this still has not stopped them. In addition, a woman in Houston, Texas is already using Liberi’s Social Security number.

Moreover, with the danger imposed by Taitz and Defend our Freedoms

Foundation, Inc., this Court must grant Plaintiffs’ Motion and Order Taitz and DOFF to immediately pay Twenty Thousand [$20,000.00] Dollars to cover all of Liberi’s and her family’s expenses to relocated Liberi, her son and husband to ensure Taitz and Defend our Freedoms Foundation, Inc.’s threats are not carried out. Liberi as well as the entire

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Plaintiffs’ are scared to death and are very concerned about their own lives, the lives of their children and spouses. Counsel will provide this Court will a medical letter from Plaintiff Liberi’s doctor under seal, as Liberi suffers from severe heart problems and this type of stress is likely to end her life. This Court has the inherent power to grant this type of immediate relief along with the Injunction. In Schalk v. Teledyne, Inc., 751 F. Supp. 1261 (W.D. Mich. 1990), aff'd, 948 F.2d 1290 (6th Cir. 1991), for example, the Court granted a preliminary injunction requiring the company to pay insurance premiums pending suit in part because "the uncertainty posed by the lack of knowing just how much money will be needed to cover medical expenses . . . poses irreparable harm in the financial planning burden which it places on plaintiffs," id. at 1268. The irreparable harm requirement is met if a plaintiff demonstrates a significant risk that he or she will experience harm that cannot adequately be compensated after the fact by monetary damages. See Frank's GMC Truck Center, Inc. v. General Motors Corp., 847 F.2d 100, 102-03 (3d Cir. 1988).

B.

Plaintiff Has A Very Strong Likelihood of Success on the Merits of this Case and Plaintiffs’ will Suffer Irreparable Harm without the issuance of the Emergency Injunction or Restraining Order:

Defendants’ have violated Plaintiffs’ First and Fourteenth Amendment violations; illegal disclosure of a person’s Social Security number, date of birth, mother’s maiden name, where one was born, etc. (CA Civil Code 1798 et sequitur); Invasion of Privacy; Right to Privacy; Right of Publicity; harassment; endangerment; publication of private facts; false light invasion of privacy; slander; libel; false designations and description of

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facts in violation of 15 U.S.C. § 1125, Cyber Harassment, Cyber Stalking, Cyber Invasion of Privacy and Cyber Right to Privacy. Plaintiffs’ are in possession of the postings, e-mails sent around the United States and Internationally as well as copies of all the audio shows. Plaintiffs are also in possession of Taitz Dossier #6, wherein she displays all of Liberi’s personal identifying information including Liberi’s full Social Security number. Plaintiffs’ are in possession of all the e-mails distributed by Taitz, Defend our Freedoms Foundation, Inc., Sankey, the Sankey Firm, Sankey Investigations, Belcher, Mr. and Mrs. Hale, Plains Radio, Bar H and KPRN. Taitz, Defend our Freedoms Foundation, Inc., Sankey, the Sankey Firm, Sankey Investigations, Belcher, Mr. and Mrs. Hale, Plains Radio, Bar H and KPRN e-mails, postings, publishing’s and radio shows not only have been dangerous to the Plaintiffs’, they are slanderous and libelous and not only placing Liberi and the other Defendants in danger, they are damaging the Plaintiffs’ businesses. Moreover, none of the Defendants’ have stated any type of defense nor have they raised affirmative defenses that are now waived. Default was entered May 27, 2009 against three [3] of the Defendants, Taitz, et al, Defend our Freedoms Foundation, Inc. and The Sankey Firm. In addition, other than Taitz and Defend our Freedoms Foundation, Inc.’s untimely and inappropriate filings, none of the Defendants’ have filed any type of Response or Opposition to Plaintiffs’ Motion for an Emergency Injunction and/or TRO. As for Taitz and Defend our Freedoms Foundation, Inc., they were without “Standing” before this Court to file any documents other than unliquidated damages, as Default had

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been previously entered. See Sierra Foods, Inc. v. Haddon House Food Prods., Inc., 1992 U.S. Dist. LEXIS 16667 (E.D. Pa. Sept. 22, 1992) at *14 noting “in MOORE'S FEDERAL PRACTICE, "The defaulting party []loses his standing before the court and his right to present evidence on issues other than unliquidated damages." 6 James W. Moore, et al., MOORE'S FEDERAL PRACTICE, P 55.03[2] (2d ed. 1991). Thus, as long as the Default remains in effect, the pleadings are closed and Defendants are not entitled to put in issue their version of the facts alleged by Plaintiffs’, which is the substantive result of Taitz and DOFF’s failure to timely Answer Plaintiffs’ Complaint on the record of this case and the Entry of Default. See Kaplan v. Morse, 870 So. 2d 934 (Fla. Dist. Ct. App. 5th Dist. 2004) at *5 (“A default generally terminates a party’s right to further defend, except to contest unliquidated damages.”); Dalton-Ingersoll Co. v. Fiske, 175 Mass. 15, 20 (1899), ("[a] person defaulted has no standing in court except to take off the default."); Thomson v. Wooster, 114 U.S. 104, 5 S.Ct. 788, 29 L.Ed. 105 (1885) (It is the law that once a default is entered, a defendant on default has no further standing to contest the factual allegations of plaintiff's claim for relief). By virtue of the Default, the truths of Plaintiffs’ well-pleaded allegations are Admitted. They may not be contested on the merits, and have the same effect as if established by proof. DIRECTV, Inc. v. Crumlish, 2004 U.S. Dist. LEXIS 13680 (E.D. Pa. July 16, 2004); Comdyne I, Inc. v. Corbin, 908 F.2d 1142 (3d Cir. 1990) (quoting 10 Charles A. Wright et al., Federal Practice and Procedure, § 2688 at 444 (1983) (citing Thomson v. Wooster, 114 U.S. 104, 5 S. Ct. 788, 29 L. Ed. 105 (1885)); Duncan v. Lord, 409 F. Supp. 687, 691 (E.D. Pa. 1976) quoting Trans World Airlines, Inc. v. Hughes, 38 F.R.D. 499 (S.D.N.Y. 1965); United States v. Borchers, 163 F.2d 347 (2 Cir. 1947)

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(When a Court determines, . . . that a defendant is in default, its liability to the plaintiff is deemed established and the plaintiff is not required to establish his right to recover.). See also I.C.C. v. Smith, 82 F.Supp.39 (D.C.Pa.1949).

Defendant is deemed to have

Admitted all well pleaded allegations in the Complaint.

At the most, all that

Defendant can do is question the extent of the damages suffered by the Plaintiffs’. Trans World Airline, Inc. v. Hughes, 332 F.2d 602 (2d Cir. 1964), reversed on other grounds, 409 U.S. 363, 93 S.Ct. 647, 34 L.Ed.2d 577 (1973). See Caribbean Produce Exchange v. Caribe Hydro-Trailer, Inc., 65 F.R.D. 46, 48 (D.C. Puerto Rico 1974) (subsequent to entry of default, defendant's argument of a late propounded affirmative defense was improper). Taylor v. City of Ballwin, Missouri, et al, 859 F.2d 1330 (1988) (same), quoting Caribbean, supra and Thomson, supra. An important factor animating our holding is our respect for the extraordinary nature of the preliminary injunction power. We have repeatedly insisted that the use of judicial power to arrange relationships prior to a full determination on the merits is a weighty matter, and the preliminary injunction device should not be exercised unless the moving party shows that it specifically and personally risks irreparable harm. See, e.g., Campbell Soup Co. v. ConAgra Inc., 977 F.2d 86, 91 (3d Cir. 1992); Frank's GMC Truck Center, 847 F.2d at 102-03. This clearly has been met as all the Defendants’ have waived their right to any affirmative defenses and have failed to cite any type of defenses in their Answers, thus the allegations in Plaintiffs’ Complaint are deemed admitted.

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B.

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There Will Be Minimal Harm to the Defendants’ if Relief is Granted and The Public Interest Supports a Grant of Relief:

Granting Plaintiffs’ Motion for an Emergency Injunction or Restraining Order will result in negligible harm, if any, to Defendants’ as Plaintiffs’ are merely attempting to protect their private confidential information; their privacy; false information being sent out, etc. Consideration of the relative harm to the Defendant and the public interest also weighs heavily in favor of Plaintiffs’. See Adams, 204 F.3d at 484 (noting district court should consider these two elements where relevant). First, the irreparable harm Plaintiffs would suffer in the absence of a preliminary injunction substantially outweighs the harm to the Defendants’ from the preliminary injunction ordered. Moreover, issuing a preliminary injunction against the Defendants’ will not adversely affect the public interest. To the contrary, the prevention of First and Fourteenth Amendment violations; illegal disclosure of a person’s Social Security number, date of birth, mother’s maiden name, where one was born, etc. (CA Civil Code 1798 et sequitur); Invasion of Privacy; Right to Privacy; Right of Publicity; harassment; endangerment; publication of private facts; false light invasion of privacy; slander; libel; false designations and description of facts in violation of 15 U.S.C. § 1125, Cyber Harassment, Cyber Stalking, Cyber Invasion of Privacy, Cyber Right to Privacy, even that affecting only private citizens, is in the general public interest." F.T. Int'l, Ltd. v. Mason, 2000 U.S. Dist. LEXIS 14979 (E.D. Pa. Oct. 11, 2000), at *2. See also United States ex rel. Rahman v. Oncology Assocs., 198 F.3d 489, 496-97 (4th Cir. 1999).

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III.

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CONCLUSION

Plaintiffs’ have demonstrated a very strong likelihood of success that Plaintiffs’ will suffer irreparable injury, if relief is denied; the balance of hardships imposes little burden on the Defendants’; and the public interest supports the granting of the requested relief. For the above aforementioned reasons, this Honorable Court should grant Plaintiffs’ request for an Emergency Injunction or Restraining Order and Order the following: A.

Grant Plaintiffs Motion for an Emergency Injunction and/or

Restraining Order prohibiting the Defendants’ from any further slander and/or libel; B.

An immediate Order enjoining the Defendants’ Orly Taitz, Esquire

a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey Firm, Sankey Investigations, Inc; Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Braun a/k/a Web Sergeant a/k/a Katy a/k/a www.obamacitizenshipdebate.org; Edgar (Ed) Hale a/k/a JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains Radio; and KPRN AM 1610 and all parties acting on their behalf from airing and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi, Philip J. Berg, Esquire, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa Ostella, Go Excel Global, the Plaintiffs’ family members, etc. via the internet or any other print or electronic medium or broadcasts and/or radio, from portraying

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Plaintiffs’ in a false-light via the internet or another print or electronic medium or broadcasts and/or radio, untrue statements about the Plaintiffs’; enjoin the Defendants’ from any further harassment of the Plaintiffs’, enjoin Defendants’ from the filing and reporting of falsified criminal activity, etc. C.

An immediate Order enjoining Defendants Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party on their behalf from disseminating Liberi’s Social Security number, date of birth, name, where she was born, mother’s maiden name, where she lives, etc. D.

An immediate Order of Retraction against Defendants’ Taitz,

Defend our Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party who has published Liberi’s confidential information on their behalves to immediately retract and remove Liberi’s private confidential information, including but not limited to her Social Security number, date of birth, where she resides, her mother’s maiden name, where she was born, information about her husband, etc. E.

A Court Order directed at the Social Security Administration for

the Social Security Administration to issue Lisa Liberi a new Social Security number; F.

An immediate Order that Defendant Orly Taitz, Esquire and

Defend our Freedoms Foundation, Inc. immediately pay Twenty Thousand [$20,000.00] Dollars within seventy-two [72] hours through this Court payable to Plaintiff Lisa Liberi for the relocation of Mrs. Liberi and her family as a result of

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the private confidential information Mrs. Taitz has posted, sent out via e-mail, sent out through the Internet RSS feed, etc. G.

Grant Plaintiffs’ Attorney fees in the amount of Five Thousand

Dollars [$5,000.00] payable to Philip J. Berg, Esquire within Seventy-Two [72] hours and such other and further relief as the Court deems just and proper.

Respectfully submitted,

Dated: June 23, 2009

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s/ Philip J. Berg _____________________________ Philip J. Berg, Esquire Attorney for the Plaintiffs’ 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134

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http://www.orlytaitzesq.com/blog1/?p=2522 Dr. Orly Taitz Esquire Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691 Copyright 2009 « Previous Post Ties to Everett, need help with research ,

You mentioned Everett, Wash. connection with Barack Obama’s mother’s family. Just wondering if you knew that connection went back for over a century…

http://www.heraldnet.com/apps/pbcs.dll/article?AID=/20081026/NEWS01/710269867

Plus a bit more about the Wolfleys: http://www.santacruzsentinel.com/world/ci_12517525 So with a POTUS with a Muslim father and German roots mother, why shouldn’t Israelis be worried? If you do post this info, please don’t mention my name or email. Cheers Response I am really concerned about several coincidences 1. a man who threatened to shoot me and burn my body for the world to see was tracked to a computer server in Everett WA. Another person that threatened me was traced to Chauhelis WA and yet another one to Canada (from what I understand not far from the border with WA state). A few days after the threat there was a clamp missing and a disconnected fumes emissions hose in my car and my husbands car died, suddenly a fuse was missing. 2. Obama does not talk about it, but his mother wasn’t in HI when he was a baby, she was enrolled in the U of Seattle WA from August 1961-till June 1962, which means that as a baby he lived in WA. 3. Lisa Liberi, assistant for Berg, who has a lengthy criminal record of grand theft, forgery of documents and forgery of official seal doesn’t talk about it, but according to records she was born in WA state. From what I recall Bellview WA. (her name at birth was Lisa Richardson. From what I recall father -Jack Richardson, mother Shirley Wadell)

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4. Obama, Liberi and Obama’s mother Stanley Ann Dunham- all have multiple social security numbers according to databases. 5. Liberi was convicted of forgery of documents and according to experts, there are multiple signs of forgery in Obama’s documents. 6. Stanley Ann Dunham also went by the name Shirley Ann Dunham. We found a Dunham organization, owned by Shirley Ann Dunham; one location was in Seattle another in Bellview WA. They dealt with insurances, lawyers, mortgages- you can get ss numbers from all of these records. 7. From what I recall, there was a discrepancy between Intellius records and Secretary of state records. According to the sec. of state a man owned that co. One of our volunteers pulled court records in Bellview for the Dunham organization. This man, Mr. Dunham (don’t remember first name) kept changing his middle initial in several court cases, which was suspicious by itself. 8. There was a very strange newspaper article in WA (I believe Seattle), from what I recall, when Obama supposedly was in Columbia. It stated that one, Roman Obama studied at the university of Patrice Lumumba in Moscow, Russia, and had some financial difficulties. 9. When grandma Dunham got sick, a reporter from WA (I believe Seattle) has writen an interview with Charles Payne, saying the grandma got a broken hip. She was dead of cancer a few days later. I was wondering, why did it come out in WA, and not HI or IL? 10. Based on all of the above, I have a nagging feeling, that there is somebody there in WA, some relative of Obama, somebody who we might think is no longer with us. This entry was posted on Monday, June 22nd, 2009 at 3:35 pm and is filed under Uncategorized. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.

[emphasis added]

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http://www.lexis.com/research/smb/tp/legalhome/?_b=0_421767556 View: Results List | Full

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NASH, SHOLANDA

Address:

910 CYPRESS STATION DR. APT HOUSTON, TX 770901502 HARRIS COUNTY 622-19-XXXX

SSN:

Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes entered poorly, processed incorrectly and is generally not free from defect. This system should not be relied upon as definitively accurate. Before relying on any data this system supplies, it should be independently verified. For Secretary of State documents, the following data is for information purposes only and is not an official record. Certified copies may be obtained from that individual state's Department of State.

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910 CYPRESS STATION DR APT HOUSTON, TX 770901502 HARRIS COU

622-19-XXXX(2000) SSN linked to multiple people

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http://www.orlytaitzesq.com/blog1/?p=36 Dr. Orly Taitz Esquire Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691 Copyright 2009 « KY secretary of state Million Patriots march » Follow up on Lisa Liberi, paralegal to Phil Berg In regards to Lisa Liberi, assistant to Phil Berg. As I stated, she has an extensive criminal record of forgery, forgery of seal, grand theft and so on. Lisa Liberi was stating that it is not her, that it is another Lisa Liber, and that she lives in PA and not NM, however this is not true. She lives in NM, her home phone number and address is in NM and this can be verified with the probation officer Joanne Martinez fax 505-476-2368, phone 505-8278627. I corresponded with John Hemenway ESQ, who filed Hollister v Soetoro case in DC for Phil Berg and he stated that Lisa Liberi, who works for Berg lives in NM. When his son was buying a truck in NM, she told him, that she lives there and can assist. One of former volunteers for Phil Berg has written a statement and went with me to FBI in San Antonio and reported that Lisa Liberi, who works for Berg lives in Santa Fe, NM and she sent Christmas presents to Lisa to NM. Today many employees and volunteers work from home and correspond via e-mails and phone calls. This volunteer stated that Lisa Liberi corresponds via e-mails and phone. A person will not make a report with FBI and risk going to jail unless she provides a truthful statement. She also recorded this statement on video. I had three confirmations from 3 independent sources of the findings of licensed investigator Mr. Sankey Before I posted dossier #6. After all the revelations the name of Lisa Liberi in Mr. Berg’s site was changed to Agent88. I believe, that when non-profit organizations are involved and donations are collected, one should not employ people that are questionable and particularly people that have a lengthy criminal record that includes forgery, forgery of seals and grand theft. I have closed the pay pal account, when I saw that Lisa Ostella has redirected the the Defend Our Freedoms blog and redirected the pay pal. Now there is no pay-pal for this foundation and there will not be any more questions. I will be setting a direct visa/credit card donation button , where donations will go directly to the foundation, so there will not be a problem of someone redirecting donations by changing the e-mail address on the pay pal button. Yet another important matter. So far none of Obama eligibility matters have gone to trial and we all are working hard to change it. But let’s say one such case goes to trial. We

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don’t want to be impeached by Obama’s attorneys saying that we knowingly employed shady characters, who might’ve supplied us with incorrect information. Just like the country needs to be purged of Obama and his clique, that are in power by virtue of forgery, fraud and consealment of vital records, the patriots of this country need to purge their ranks. This entry was posted on Saturday, April 18th, 2009 at 2:29 pm and is filed under Other Criminal or Suspicious Activities. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.

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[emphasis added]

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Law Offices of: Philip J. Berg, Esquire 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134

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Attorney for Plaintiffs

UNITED STATES DISTRICT COURT, FOR THE EASTERN DISTRICT OF PENNSYLVANIA LISA LIBERI, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.

: : : : : : Case No.: 09-cv-01898-ECR : : : :

CERTIFICATE OF SERVICE I, Philip J. Berg, Esquire, hereby certify that a copy of Plaintiffs’ Emergency Motion for the Issuance of Plaintiffs’ Injunction or Restraining Order Requested Plaintiffs’ Motion filed and Docketed as Document No. 3 on May 27, 2009 was served this 23rd day of June 2009 electronically upon the following:

Orly Taitz, et al. 31912 Monarch Crest Laguna Niguel, CA 92677 Email: [email protected] Defend our Freedoms Foundation, Inc. a/k/a Defend our Freedoms Foundation 26302 La Paz, Suite 211 Mission Viejo, CA 92691 Email: [email protected]

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The Sankey Firm Sankey Investigations 2470 Stearns Street #162 Simi Valley, CA 93063 Email: [email protected]

James Sundquist and Rock Salt Publishing 551 Valley Road #123 Upper Montclair, NJ 07043 Email: [email protected] Mr. Ted Hoppe, Esquire Hoppe & Martin 423 McFarlan Road, Suite 100 Kennett Square, PA 19348 Email: [email protected] Attorney for Defendants: Ed Hale Caren Hale Plains Radio KPRN Bar H Farms Linda Sue Belcher Neil Sankey

s/ Philip J. Berg ________________________ PHILIP J. BERG, ESQUIRE Attorney for Plaintiffs’

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